Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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Form 10-IC filed within the applicable due date preserved the option for the concessional corporate tax regime, because the due date under section 139(1) depends on the assessee's class and is not advanced merely by belated filing of Form 3CEB or an incorrect return selection. The text notes that later furnishing of the transfer-pricing report before assessment did not justify denial of the option. Once the option under section 115BAA was validly exercised, tax had to be computed under that regime and MAT under section 115JB could not be applied.
Form 10-IC filed within the applicable due date preserved the option for the concessional corporate tax regime, because the due date under section 139(1) depends on the assessee's class and is not advanced merely by belated filing of Form 3CEB or an incorrect return selection. The text notes that later furnishing of the transfer-pricing report before assessment did not justify denial of the option. Once the option under section 115BAA was validly exercised, tax had to be computed under that regime and MAT under section 115JB could not be applied.
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